1984) (holding that it was not an unlawful employment practice for officials at a Jesuit university to hire and employ members of their own religious community rather than a non-Catholic applicant for designated positions teaching philosophy where being Catholic was a BFOQ reasonably necessary to further operational goals).

And, in this respect, Justice Marshall's concerns regarding the malleability of the BFOQ were prescient, not only in the context of the BFOQ defense itself but also in the related analysis employed in the "business-necessity" defense announced the following year in Griggs.

firm Fowler White Boggs, said a BFOQ defense in this case would be a difficult one to mount because the credit union would have to show that there was something about working at PSFCU that only Poles could do.

This exception, entitled a BFOQ (Bona Fide Occupational Qualification), permits organizations to base employment decisions on religious preference, gender or national origin if it can be demonstrated that these specific socio-demographic characteristics are "reasonably necessary to the normal operation of that particular business or enterprise" (42 U.

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